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34, at 5 (acct. Nos. 1210 and 1211); Exh. 5911, at 10 (AJE 28,
lines 15-19). IRA claimed a bad debt loss with respect to
Ballard’s and Lisle’s notes on its tax return for 1987. Exh. 22.
By the end of 1987, IRA still held a receivable of $485,825
due from HELO and a receivable of $345,869 due from Cedilla
Investment Co. Exh. 9189. On December 22, 1987, IRA sold to MAF
for $1 the HELO and Cedilla Investment Co. receivables totaling
$831,692. Exh. 34, at 13, first entry; Exh. 5911 (AJE 32, last
page).
On December 22, 1987, IRA also sold its interest in 1984
Development Partnership to MAF for a promissory note for $1,000.
Exh. 9189. IRA claimed a long-term capital loss of $22,862
attributable to this transaction on its 1987 tax return. Exh.
22, Schedule D.
Morrison (through MAF) entered into the transactions with
IRA described above merely as an accommodation to Kanter.
Morrison, Transcr. at 4530. After purchasing the notes from IRA,
MAF did no other business. Morrison, Transcr. at 4517.
By the end of 1987, neither Ballard nor Lisle owed any
portion of their original loans totaling $196,648 and $28,284,
respectively, to either IRA or IFI. CMB Cinema Ventures no
longer owed $250 to either IRA or IFI. Likewise, Ballard’s and
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